For nurse practitioners · California

The door is open. Put your name on it.

For the first time, a California nurse practitioner can run a practice with no physician attached to it. Gale is the practice OS for the NP who walks through — cash- and HSA-first, free software, an automatic back office, and a public page that is yours.

Find your page — we rank for your name →The 103/104 guide
The moment

What changed this year

AB 890 wrote a ladder into the Business and Professions Code in 2020: first a transition to practice — three full-time-equivalent years or 4,600 hours, completed in California (§2837.103) — then at least three further years in good standing as a 103 NP (§2837.104). The board could not create the 103 certificate until early 2023, and said from the start that it would not be able to certify 104 NPs until 2026. That year has arrived: the application opened in BreEZe in early 2026, and the first NPs in California history to practice with no physician attached are filing now.

It is early enough that the board publishes no 104 count and no 104 processing-time estimate. Employers, credentialing committees, and carriers are still forming their reference points for what the certificate means. A patient searching for care meets the NP-owned practice as a new kind of thing — and the practices founded in this window get to define what it looks like.

The ladder also has a trap on its lowest rung: an NP who opens her own entity too early can stall her own clock, because the hours that count toward the 104 must be earned as a 103, in a setting the statute lists — and her own corporation is not one of them. The details, with citations, are in the guides below.

Receipts, not testimonials

Other platforms would show you quotes here. Gale has no founding NPs to quote yet, and we do not invent people — so here are the regulatory numbers instead, each dated, each sourced, each carried with its full citation in the guides below.

2026

The year the board said it could first certify 104 NPs — “the application to become a 104 NP will not be available until 2026.” It opened in BreEZe in early 2026.

BRN news release, Feb 2, 2023 · BRN 104 application instructions

Jan 2023

The 103 certificate is created — the ladder’s first rung did not exist before this date.

BRN Sunset Review Report 2026, Table 7a footnote

2,722

103 certifications issued across FY 2022/23–2024/25 (843, then 1,030, then 849).

BRN Sunset Review Report 2026, Table 7a

≈45,838

Nurse practitioners the BRN oversees. On the order of six percent hold a 103 — a rough share drawn from two differently dated tables, not a precise rate.

Senate B&P background paper, March 2026 · BRN Sunset 2026

35 days

Average processing time for a complete 103 application in FY 2024/25 (78 days the year before).

BRN Sunset Review Report 2026, Table 7a

None

Published count of 104 certificates issued so far. The board’s processing-times table, updated 21 July 2026, carries no 104 row yet.

BRN Processing Times · BRN Sunset Review Report 2026

What Gale runs

The inventory, split honestly. Nothing dark is dressed as live.

In the product today

  • Scheduling and the calendar.
  • Notes, with a scribe that drafts during the visit — you stay the final editor of every note.
  • Telehealth where the chart lives.
  • The patient record — see a sample chart, no signup.
  • Superbills for the patient who wants to claim out-of-network benefits.
  • The Fee Schedule — the one Gale document that states the fee.
  • Your practice page, in the public directory compiled from the NPPES registry.

Opening with the founding cohort

  • Concierge memberships — a monthly plan your practice sells on its own terms. Not sellable yet: enrollment fails closed behind a legal switch until counsel clears it. No countdown — when it clears, it clears.
  • The loop tracker — every referral, lab, and question a visible loop with an owner, a state, and a promised window. Closing one requires an outcome note; nothing silently expires.
  • The guided founding sequence — practice setup walked step by step with the first cohort: entity, posted prices, the practice page, the first visit.
Where NP independence is possible

Thirty-six jurisdictions, three ways in

California is one door among many. Twenty states and territories attach independence to the license itself; fourteen put a transition between licensure and independence; two make it a designation you register for. Every entry links to the dated, sourced page for that jurisdiction — and a state that is not listed has no NP independence pathway yet.

36 of 36 jurisdictions

At licensure · 20

After a transition · 14

By registration or designation · 2

The economics

Retiring the rent on the license

Short of full practice authority, a practice keeps a physician attached — standardized procedures here, a collaborating physician in other states — and the attachment has a price. The national matching services that publish rates listed monthly fees from $780 to $1,425 in a January 2025 compilation of vendor pricing, with initiation fees up to $500 at some. Our own guide declines to call any of that a benchmark: it is a private market, and a quoted figure is a market observation, not a going rate.

The 104 retires that line. What replaces it is not a smaller fee but a set of duties — a scope limit tied to your certification, four mandatory physician-consultation triggers, and a written referral plan (BPC §2837.104(c)) — spelled out here. The recurring cost goes to zero; the professional obligations remain, and they are yours.

Gale’s side of the ledger is deliberately short. The software is free, and Gale earns one flat all-in fee on a transaction — charged only when your practice is actually paid, never as a subscription, never with per-feature line items, never a spread on your rate. The number itself lives in exactly one document, on purpose, so it can never quietly say two different things in two places: the Fee Schedule states it.
The guides

Eight pages written for exactly this decision — cited to the statute and to the board’s own filings. Every number above is carried in them, with its full citation.

NP · CaliforniaWhat Is a 103 NP in California? The Certificate, Read PlainlyA 103 NP is a California nurse practitioner certified under Business and Professions Code §2837.103 to perform six enumerated functions without standardized procedures —…NP · CaliforniaWhat Is a 104 NP in California? Independent Practice, and Its Real LimitsA 104 NP is a California nurse practitioner certified under Business and Professions Code §2837.104 to perform the §2837.103(c) functions without standardized procedures…NP · California103 NP vs. 104 NP in California: The Setting Is the Whole DifferenceThe 103 and 104 certificates authorize the identical six functions listed in Business and Professions Code §2837.103(c). The difference is location.NP · CaliforniaThe 4,600-Hour Transition to Practice: What California Actually CountsCalifornia requires a transition to practice of a minimum of three full-time-equivalent years of practice or 4,600 hours, and Business and Professions Code…NP · CaliforniaHow to Apply for 104 NP Certification With the California BRNCalifornia nurse practitioners became eligible for 104 status on January 1, 2026, and the Board of Registered Nursing now publishes a live application.NP · CaliforniaDo 104 NPs Still Need Standardized Procedures? No — Here Is What Replaces ThemNo. A certified 104 NP performs the §2837.103(c) functions without standardized procedures, outside physician-staffed settings.NP · CaliforniaMoving to California as an Out-of-State NP: The Independence Clock RestartsCalifornia requires the transition to practice be completed in California (BPC §2837.103(a)(1)(D)), so independent practice in another state currently counts for nothing…NP · CaliforniaSB 1451 and California NPs: What Changed, and What Older Guides Still Get WrongSB 1451 (Ashby, Chapter 481, Statutes of 2024) amended AB 890's nurse practitioner article effective January 1, 2025.
Questions with citable answers
Owning is legal; using the certificate inside it is not. A nursing corporation can be NP-owned, but it is not among the six settings BPC §2837.103(a)(2) lists, so the BRN is explicit that an NP working in a nursing corporation cannot practice there as a 103 NP without standardized procedures. And the hours that count toward the 104 must be earned after 103 designation, as a 103 — so opening your own practice too early can stall the clock that gets you to independence. Sequence first, then the door.
No. Both certificates authorize the same six functions in BPC §2837.103(c). The 104 removes the setting restriction — a solo office, your own corporation, a telehealth panel you own — not the scope ceiling. BPC §2837.104(c)(1) still confines practice to your education, training, knowledge, experience, and national certification.
It is a real boundary, not a formality. The BRN’s own summary is that a 104 NP may work independently within the population focus of their national certification — so a family-certified NP does not acquire a psychiatric panel on the strength of the certificate, and vice versa. Practice follows the certification you actually hold.
No. BPC §2837.104(b)(3) requires at least three years of practice in good standing, not inclusive of the transition to practice, and the BRN reads that through 16 CCR 1482.4 as three full-time-equivalent years or 4,600 hours of direct patient care after 103 designation. The two periods stack; they do not overlap.
No. The BRN states that moving to 103 or 104 status is optional and the traditional NP role continues unchanged — standardized procedures remain available either way, and no employer is required to demand the certificate. The 104 matters when you want a practice with your own name on the door.
A monthly plan your practice sells on its own terms — your contract with your patient, priced under the Internal Revenue Code’s HSA-compatibility rails, which the software enforces. It is not open today: no membership is offered or sold, and the selling switch fails closed until counsel clears it. When it opens, Gale services the billing as the practice’s agent — never a retained spread. The terms live in the Fee Schedule.
Cash- and HSA-first by design. You post your price; the patient pays the practice directly, HSA and FSA funds welcome; the software generates superbills a patient can submit to their own plan. Gale’s fee is charged to the practice, never to the patient, and only on transactions that actually pay — stated in the Fee Schedule.
Where to start

Your page may already exist

Gale publishes a public directory compiled from the NPPES registry. Find your listing, claim it, and see how you rank for your own name — that page is the front door your independent practice will be found through.

Find your page — we rank for your name →Browse the provider hub